Court: Supreme Court of the United States; December 5, 1949; Federal Supreme Court; Federal Appellate Court
The case of Boyd v. Grand Trunk Western R. Co. addresses the validity of a contractual agreement that restricts the choice of venue for actions under the Federal Employers' Liability Act (FELA). The petitioner, an employee injured while working for the respondent railroad, signed agreements stipulating that any lawsuit must be filed in specific Michigan jurisdictions. However, the petitioner initiated legal action in Illinois. The respondent sought to enjoin this action, leading to a dispute over the enforceability of the venue restriction.
The Michigan Circuit Court deemed the venue restriction void, but the Michigan Supreme Court reversed this decision. The U.S. Supreme Court, upon granting certiorari, aligned with decisions that deemed such contracts void as they conflict with FELA. Specifically, Section 6 of FELA allows actions to be brought in various jurisdictions, including where the defendant resides or where the cause of action arose, and emphasizes the concurrent jurisdiction of state and federal courts. The Court affirmed that the petitioner's right to sue in any eligible forum is a fundamental aspect of FELA, and any contractual limitation intended to exempt a carrier from liability is void.
The Court referenced precedent, particularly Duncan v. Thompson, reinforcing that agreements limiting venue, even if signed post-injury, cannot contravene the rights established under FELA. The ruling clarified that prior cases distinguishing between compromise agreements and venue restrictions do not alter the fundamental right to choose a venue afforded to plaintiffs under the Act. Ultimately, the Court concluded that the contract in question was invalid, maintaining the integrity of FELA's provisions.
An action can be initiated in any state or federal court where it could have previously been filed, affirming the substantial right to select the forum as outlined in Section 6. Upholding this right aligns with the Federal Employers' Liability Act's intent. The ruling is reversed, with Justices Frankfurter and Jackson concurring based on Chief Judge Hand's reasoning in Krenger v. Pennsylvania R. Co. The decision notes that any sums advanced by the common carrier may be deducted from the eventual settlement, as specified in Section 5 of the Liability Act. This section allows common carriers to set off amounts contributed to insurance or benefits related to the injury or death in question. A precedent exists where a court invalidated a waiver of venue provision due to lack of consideration (Akerly v. New York Cent. R. Co.). The ruling is supported by several cases, while others present conflicting rulings, including Krenger and Akerly. The summary provides a comprehensive overview of the legal principles, precedents, and implications surrounding the selection of forum in the context of the Federal Employers' Liability Act.
